The Cayman Islands government announced that the automatic exchange of information (AEOI) portal has re-opened, allowing Cayman Islands financial institutions to submit their 2017 FATCA and CRS returns. Various updated guides and forms are also now available on the Cayman Islands Tax Information Authority (TIA) website:
- CRS Guidance Notes including clarifying the requirements for closing accounts and AEOI compliance obligations after a financial institution has been dissolved
- AEOI Portal User Guide
- Entity Self-Certification Form, this is to be used for all new entity accounts and includes a new 10% (instead of 25%) controlling ownership interest threshold for CRS for an entity that is a legal person, to reflect the amended Anti-Money Laundering Regulations 2017. There is no change to the 25% controlling person threshold for FATCA compliance.
What are the 2018 deadlines for Cayman Islands financial institutions?
30 April 2018: new Cayman financial institutions established in 2017 and before 30 April 2018 must register on the portal for FATCA and CRS compliance.
31 May 2018: deadline for 2017 FATCA and CRS reports to be submitted to the TIA via the portal.
31 December 2018: for CRS compliance, all Cayman financial institutions must obtain new entity self certification forms using the updated template for all pre-existing accounts on 31 January 2018 held by legal persons that were previously required to disclose their controlling person under Cayman Islands CRS laws.
Please contact your usual Harneys contact for further details of these changes, if you would like advice on any aspect of the AEOI regime in Cayman and how to comply with it or if you have any other questions or visit harneys.com/Cayman.